30 September 2018 is the date by which all existing "in-scope" Cayman Islands investment entities must have appointed AML Officers. As discussed in recent client updates, entities will be "in-scope" if they conduct "relevant financial business" in or from within the Cayman Islands. This will include all Cayman Islands investment entities, whether regulated or unregulated (including all hedge funds and private equity funds), structured finance vehicles and entities conducting securities investment business.

As clients of this firm will be aware from our previous communications and updates, all persons registered with the Cayman Islands Monetary Authority ("CIMA") as "Excluded Persons" under the Securities Investment Business Law (2015 Revision) ("SIBL") are regarded as carrying on "securities investment business", and therefore remain within the scope of the Cayman Islands Anti-Money Laundering Regulations (the "AML Regulations") and must continue to ensure that they comply with the requirements of the AML Regulations.

CIMA has recently contacted certain persons registered as Excluded Persons under SIBL requiring them to obtain and provide an audit report (the "Report") on the entity's AML procedures and compliance with the AML Regulations.

Pursuant to an industry advisory dated 29 May 2018, the Department for International Tax Cooperation has made announcements with respect to the availability of the AEOI Portal over the coming months and with respect to a soft extension for completion of filing requirements.

This update serves to advise our BVI clients of upcoming important filing deadlines as well as procedures for submission of information to the relevant authorities with regard to audited accounts, fund annual returns, record keeping, register of directors and AEOI.